Relay, Inc. Attn: Privacy 4200 Six Forks Road, Suite 1800 Raleigh, N.C. 27609 Tel. 919 230-4307
What personal information do we collect and what choices are available for you to manage the personal information collected?
Upon Activation of Your Relay Device(s)
There is one account owner for all of the Relay devices on an account (the “Account Owner”). The Account Owner must have a valid credit card, be over the age of 18, and be the parent if you have children on an account. We will ask for certain information, such as name, email, physical and billing address, from you, the Account Owner, upon activation. The Account Owner also will enter credit card information, which is not collected or retained by us but is retained by our credit card processing vendor(s). Relay device(s) need to be paired with the Companion App and activated before they will function. As part of the activation, the Account Owner will have an opportunity to modify the ID name (an “ID Name”) that is pre-assigned upon shipment for each Relay device. These ID Names are collected and retained by Relay in order for us to provide you with the Services. We do not use the ID Names for any marketing purposes and do not share the ID Names with third-parties for any marketing purposes. We may share the ID Names with third-parties with whom we have contracted for service and support services if providing the ID Name(s) is necessary in order to resolve your service or support issue. We recommend that you do not use any personal information if you choose to modify the pre-assigned ID Name.
When a Relay device is synced to the Companion App, Relay retains in its network and servers a unique identifier code for that Relay device. In this manner, Relay knows and maintains what Relay devices are approved devices (“Approved Devices”) on your account. This unique identifier code will not contain any of your personal information. This unique identifier code is also unique to the Relay service and will not be used to track you across websites or online services.
Approved Relay devices in an Account Owner’s account can communicate with each other. We call this a communication channel (a “Channel”). Relay devices communicate through voice in a “push-to-talk” manner. When a user pushes the “Relay button” and talks here’s what happens:
The voice message is transferred over a cellular network or Wi-Fi (or a combination of both depending on the network connections available) to our servers. Our servers recognize the Relay device and the other Approved Devices for that Relay device in that particular Channel. Our server then forwards that voice message to the other Approved Devices, and the message is played by the Approved Devices. We do not retain the message or the contents of the message in our servers or network. Unless you use a compatible headset with the headset jack, Relay messages are played similar to a walkie-talkie or speaker phone and someone in proximity of a Relay device could overhear all or part of a message.
Adding/Removing Relay Devices to a Channel
From time to time, users may wish to add or remove Relay devices to a Channel. Adding a Relay device to a Channel requires the approval of the Account Owner for the Relay device that is going to be added and the Account Owner of the Relay device that is the owner of the Channel. For example, if a Channel consists of 2 Relay devices, one owned by Account Owner #1, who is also the owner of the Channel, and one Relay device owned by Account Owner #2, and then a new Relay device owned by Account Owner #3 wants to join the Channel, Account Owner #1 and #3 must both approve the new Relay device for the Channel. If one Account Owner does not approve, the new Relay device will not be added to the Channel. Once the Account Owners approve, the new Relay device will become an Approved Device for that Channel. When a Relay device is added to a Channel, Relay will retain in its network and servers the unique identifier code for the added Relay device that is now approved to be part of the Channel.
If an Account Owner wants to remove a Relay device from a Channel, the Account Owner of the Relay device can remove it. Take our previous example. If Account Owner #2 was uncertain whether they wanted to remain in a Channel with the Relay devices owned by Account Owners #1 and #3, then Account Owner #2 could remove the Relay device they owned from the Channel. When you remove a Relay device from a Channel, Relay will remove from its network and servers permission for the removed Relay device to be part of the Channel.
The Account Owner will have the choice, in the Companion App, to turn location services “on” for each Relay device. Each Relay device will have location services turned “off” as the default setting.
When location services are turned “on”, Relay will collect the following information from each Relay device that is turned “on”: The last location for a Relay device will be saved on the Relay network and its servers. Relay will retain only the most recent location for the Relay device and the time that the location was recorded. Once the Relay device has a new location or the location of a Relay device has been requested through the Companion App, the new location overwrites the old location on our network and servers and we will no longer have any record of the old, previous location. In the Companion App, if you so choose, you can keep a record of a limited number of previous locations of each Relay device. This location information is not saved on Relay’s network or servers and is only saved locally on your mobile device which contains the Companion App. You are able to erase this information from your Companion App. In addition, if a Relay device’s location services are turned to “off” in the Companion App, Relay will erase the last known location from its network and servers for that Relay device.
Future Services, Including Services That Include Features From a Third-Party
Does the Service enable children to make personal information publicly available?
Only individuals with a valid credit card are allowed to be an Account Owner. Children under 13 are not permitted to be Account Owners. However, an Account Owner can choose to allow others, including children under 13, to have a Relay device. Because we do not control what children say when speaking on Relay device, it is possible for children to divulge personal information when having a Relay conversation. Additionally, because Relay conversations are played similar to a walkie-talkie or speaker phone it is possible for someone in proximity of a Relay device to overhear all or part of a conversation. We strongly advise parents to encourage their children not to divulge any personal information in a Relay conversation.
How do we use personal information collected from children?
We do not retain the contents of any voice message and do not use the content of any voice message or location information for marketing purpose nor do we sell or make available any of this information to third-parties to use for any marketing purposes. We do not collect or use the content of any interaction of a user with a Relay device or the Services, including any personal information that may be captured therein, to contact children or for advertising purposes.
We use network tools to collect network statistics on the Relay devices and the Services used. We do this for support and service related reasons. For example, we may collect how often Relay devices and/or the Companion App are used, the length of Relay conversations, how many other Relay devices a Relay device communicates with, whether the Relay communication was successfully delivered to the other Approved Devices, the amount of a service or services used, or whether Wi-Fi or a cellular network was used. We may automatically measure and monitor network performance and the performance of a Relay device’s Internet connection to improve the Relay device, the Companion App or our overall service levels. We may collect all the type of information above, and capture information about a particular Relay device or devices, Companion App or device settings. We also may allow third-parties with whom we contract to provide support services access to this information as well as the ID Name(s) of the Relay device(s) on your account in order to allow them to provide you with support. We will collect this information for a length of time necessary to provide and monitor support and service related issues and then either anonymize or delete it. When we anonymize this information, we may use this anonymized usage information and other anonymized information for certain internal business, product, and sales purposes.
We will also use network tools to collect for each Relay device service related items, such as the battery life of the Relay device, software version being used, volume level and current Channel. This information will also appear in your Companion App so that you have access to this information.
Other Important information
At any time, parents can refuse to permit us to collect personal information from their children and can request that we delete from our records the personal information we have collected in an Account Owner’s account. Please keep in mind that a request to refuse us the ability to collect further personal information, such as sending voice messages to and from Relay devices, may lead to a termination of an account or other service. You may review and delete information that is in the Companion App. To review or request deletion of personal information you can also contact us at email@example.com
Effective November 24, 2018